DNFP 2019

2019 DECLARATION OF NON-FINANCIAL PERFORMANCE OF THE DESCOURS & CABAUD GROUP 26 > The means of control: DESCOURS & CABAUD, through its Risk Committee, has taken great pains to implement the eight measures required by law: • riskmappingbybusinesssegmentandbygeographical segment. An initial mapping of bribery risks has been produced in France on the basis of interviews with managers and front-line staff, both in terms of actual risks encountered and in terms of potential risks. This mapping is updated annually • a DESCOURS & CABAUD code of conduct for the attention of employees, appended to the company rule book: this provides the necessary keys in terms of required or prohibited conduct. In 2019, this code of conduct was translated into all the languages of the countries where the Group operates, and provided to all employees • an internal whistle-blowing procedure: this procedure, described in the code of conduct and accessible to all employees, stipulates the whistle-blowing arrangements, arrangements for protecting a whistle- blower who reports any serious breach of the code of conduct and/or the law in general. An Ethical Committee will receive the alert, analyse it and check that it is admissible, then forward it, if appropriate, to a committee tasked with conducting an investigation • a training plan intended for employees who are most exposed to the risks: a French e-learning module has been circulated to all the sales force and its management. A translation and rollout in the international subsidiaries is planned for 2020 • disciplinary measures penalising breaches of the code of conduct: they are expressly included in the latter • account auditing procedures • a system that controls and assesses the implemented measures • procedures for assessing the situation of customers and suppliers, as well as the intermediaries with whom the Group has business relations Action plans for this last measure need to be developed and implemented. The Executive Board's commitment to these anti-bribery arrangements has led the Group to adopt exemplary conduct that does not tolerate any deviation and that finds expression in a clearly asserted motto: We are all exemplary, concerned and vigilant. > Key performance indicator: Our aim is to achieve an e-learning training rate of 90% (to take account of turnover) for the anti-bribery module with regard to sales staff and their management. It should be noted that this e-learning training is considered “validated” provided that a minimum correct answer rate of 80% is obtained. If this rate is lower, the training is not validated and the trainee must commence the entire course again. Training rate Anti-bribery e-learning module: 89.6%